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Jr. (petitioner), Marjorie P. Madden (petitioner's wife), and
Cynthia Madden Leitner (petitioner's daughter). The issues
remaining for decision are:
(1) Whether the Museum of Outdoor Arts (the Museum) is
liable, as lessor, for unrelated business income tax (UBIT) on
amounts received from 1984 through 1988 in connection with the
leasing of office building spaces;
(2) whether the Museum is liable, as lessor, for UBIT on
amounts received in 1987 and 1988 in connection with the leasing
of Fiddler's Green Amphitheatre (FGA);
(3) whether Greenwood Maintenance Co.2 (GMC) is liable for
the excise tax under section 4941(a)(1) in connection with
payments received by it from the Museum from the years 1983
through 1989;
(4) whether petitioner, petitioner's wife, and petitioner's
daughter are liable for the excise tax under section 4941(a)(2)
in connection with payments made by the Museum to GMC from the
years 1983 through 1989;
(5) whether petitioner, petitioner's wife, and petitioner's
daughter are liable for the section 4941(a)(2) excise tax in
2As of Jan. 1, 1994, Plaza Developers Holdings, LLC, assumed
the assets, liabilities, and potential liabilities of Greenwood
Maintenance Co. (GMC), and GMC ceased to exist at that time.
Plaza Developers Holdings, LLC, is the named party in docket No.
6698-93. However, for clarity, we will refer to Plaza Developers
Holdings, LLC, as GMC.
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